The DOJ has issued guidelines governing investigations and the enforcement of the Foreign Corrupt Practices Act, following through on commitments made in President Trump’s February 10, 2025, Executive Order to reconsider the DOJ’s approach towards investigating and prosecuting the FCPA. These guidelines represent a targeting of FCPA enforcement and signal that the DOJ will be taking a “risk-based approach” in pursuing those matters it considers as most critical to U.S. interests. The new guidelines also continue to emphasize the importance of individual accountability, but create a window where such focus can allow for enhanced leniency with respect to corporations.